Howard M Nowlan

Decision released 30 October 2007

Income tax – Foreign earnings deduction – Definition of ‘offshore installations’ – Appeal dismissed


The taxpayer was not entitled, for the relevant tax years, to the benefit of the foreign earnings deduction for seafarers under ICTA 1988, s. 192A.


The Revenue disputed whether the vessel or structure on which the taxpayer performed his duties was a ship, and consequently whether the duties of the taxpayer’s employment were performed as a seafarer within ICTA 1988, s. 192A(2).

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